Watts hearing in Wisconsin

2023Servs., No. 2011AP152, unpublished slip op. ¶2 (WI App June 5, 2012) (concluding “circuit court lost competency to act on the guardianship petition by failing to complete the hearing within the statutorily mandated time limitation”); Brown County v. Marilyn M., No. 2005AP3051, unpublished slip op. ¶10 (WI App June 27, 2006) (determining that “the Watts rule is not a mandatory statutory time limit” so a challenge to the circuit court’s competency to proceed with a “Watts review” can be waived if not raised before the circuit court). 20 No. 2023AP757 of the commitment process and on a regular ba

2023Servs., No. 2011AP152, unpublished slip op. ¶2 (WI App June 5, 2012) (concluding “circuit court lost competency to act on the guardianship petition by failing to complete the hearing within the statutorily mandated time limitation”); Brown County v. Marilyn M., No. 2005AP3051, unpublished slip op. ¶10 (WI App June 27, 2006) (determining that “the Watts rule is not a mandatory statutory time limit” so a challenge to the circuit court’s competency to proceed with a “Watts review” can be waived if not raised before the circuit court). 20 No. 2023AP757 of the commitment process and on a regular ba

2022Servs. v. Susan H., 2010 WI App 82, ¶16 , 326 Wis. 2d 246 , 785 N.W.2d 677 . ¶15 In support of his position, Stanley points to his testimony during the Watts hearing, as well as that of Dr. Allen.

2022Servs. v. Susan H., 2010 WI App 82, ¶16 , 326 Wis. 2d 246 , 785 N.W.2d 677 . ¶15 In support of his position, Stanley points to his testimony during the Watts hearing, as well as that of Dr. Allen.

2022Therefore, reversal is the appropriate remedy in this case.” Sheboygan County v. M.W., 2022 WI 40, ¶4 , 402 Wis. 2d 1 , 974 N.W.2d 733 . 4 R.F. does not dispute the permanent guardianship in this appeal. 3 No. 2022AP481 location of his protective placement was transferred to an adult group home in Chippewa County. ¶4 The protective placement came up for annual review in 2021, with R.F. contesting it at the Watts hearing for which the County petitioned.

2022Therefore, reversal is the appropriate remedy in this case.” Sheboygan County v. M.W., 2022 WI 40, ¶4 , 402 Wis. 2d 1 , 974 N.W.2d 733 . 4 R.F. does not dispute the permanent guardianship in this appeal. 3 No. 2022AP481 location of his protective placement was transferred to an adult group home in Chippewa County. ¶4 The protective placement came up for annual review in 2021, with R.F. contesting it at the Watts hearing for which the County petitioned.

2022See § 55.18(3)(d); Watts, 122 Wis. 2d at 85 (“A full due process hearing should be required whenever the protectively placed individual … requests it.”). 4 No. 2021AP975 ¶11 A circuit court’s factual findings at a Watts hearing “will not be overturned unless clearly erroneous.” See Walworth County v. Therese B., 2003 WI App 223, ¶21 , 267 Wis. 2d 310 , 671 N.W.2d 377 (citation omitted).

2022See § 55.18(3)(d); Watts, 122 Wis. 2d at 85 (“A full due process hearing should be required whenever the protectively placed individual … requests it.”). 4 No. 2021AP975 ¶11 A circuit court’s factual findings at a Watts hearing “will not be overturned unless clearly erroneous.” See Walworth County v. Therese B., 2003 WI App 223, ¶21 , 267 Wis. 2d 310 , 671 N.W.2d 377 (citation omitted).

2022“An appellate court will search the record for evidence to support the [circuit] court’s findings of fact,” Fond du Lac County v. J.G.S., Jr., 159 Wis. 2d 685 , 687-88, 465 N.W.2d 227 (Ct. App. 1990), “not for evidence to support findings the court could have reached but did not,” Noble v. Noble, 2005 WI App 227, ¶15 , 287 Wis. 2d 699 , 706 N.W.2d 166 .

2022“An appellate court will search the record for evidence to support the [circuit] court’s findings of fact,” Fond du Lac County v. J.G.S., Jr., 159 Wis. 2d 685 , 687-88, 465 N.W.2d 227 (Ct. App. 1990), “not for evidence to support findings the court could have reached but did not,” Noble v. Noble, 2005 WI App 227, ¶15 , 287 Wis. 2d 699 , 706 N.W.2d 166 .

2022“An appellate court will search the record for evidence to support the [circuit] court’s findings of fact,” Fond du Lac County v. J.G.S., Jr., 159 Wis. 2d 685 , 687-88, 465 N.W.2d 227 (Ct. App. 1990), “not for evidence to support findings the court could have reached but did not,” Noble v. Noble, 2005 WI App 227, ¶15 , 287 Wis. 2d 699 , 706 N.W.2d 166 .

2022“An appellate court will search the record for evidence to support the [circuit] court’s findings of fact,” Fond du Lac County v. J.G.S., Jr., 159 Wis. 2d 685 , 687-88, 465 N.W.2d 227 (Ct. App. 1990), “not for evidence to support findings the court could have reached but did not,” Noble v. Noble, 2005 WI App 227, ¶15 , 287 Wis. 2d 699 , 706 N.W.2d 166 .

2016Sands frequently refers to her unjust enrichment claim as a "Watts claim." However, Watts v. Watts, 137 Wis. 2d 506 , 405 N.W.2d 303 (1987), did not create a new cause of action for unmarried cohabitants.

2002Our reasoning is supported by our analysis in Ward v. Jahnke, 220 Wis. 2d 539 , 583 N.W.2d 656 (Ct. App. 1998), where we held that a female cohabitant failed to satisfy the Watts standard because she lacked evidence of a mutual undertaking.

2002Our reasoning is supported by our analysis in Ward v. Jahnke, 220 Wis. 2d 539 , 583 N.W.2d 656 (Ct. App. 1998), where we held that a female cohabitant failed to satisfy the Watts standard because she lacked evidence of a mutual undertaking.